03/09/2026
Assembled in Thailand. Made where?
On 1 September the US Department of Commerce opened a country-wide circumvention inquiry into certain alkyl phosphate esters — chemicals finished in Thailand using intermediate materials produced in China.
Nothing has been decided. An inquiry has been opened, not concluded, and no company has been found to be circumventing anything.
But it exists at all because of the distinction that catches more businesses than any other in international trade: where goods are shipped from and where they legally originate are two different things. Duty is charged on the second one.
It is rarely deliberate. A supplier changes. An invoice names one country. The goods were finished somewhere else, from materials made somewhere else again. Nobody checks — until a customs authority does it for them, and by then the exposure is retrospective.
Three things worth knowing, whichever market you sell into:
→ "Assembled in" is not the same as "originating in." Origin turns on what was done to the goods, not the last address they passed through.
→ A change of shipping country changes nothing on its own.
→ A trade agreement existing is not the same as your goods qualifying for it. Preference has its own rules and its own evidence.
If you cannot show where your goods originate and prove it with evidence, you do not yet know your duty rate. You know your supplier's shipping address.
Full story, with the Federal Register citation:
https://hub.tradeintelligencehub.com/newsletter/assembled-in-thailand-made-where
A US circumvention inquiry opened on 1 September reopens the most expensive assumption in trade: that where goods ship from is where they legally come from.
